Referenced in our Newsletter Volume 3, Issue 8 - August 2004
Suspicious SAR-MSB Filing Data
VisuaLinks is used extensively in the detection of financial crimes and money laundering operations throughout
the world. In fact, all of the major U.S. Government agencies are utilizing VisuaLinks to help access, combine, and
analyze the Bank Secrecy Act (BSA) data. Not too long ago, a compliance analysis was presented on Money Services
Businesses (MSBs) in the Volume 2, Issue 10 - October 2003
issue of the LinkLetter. This month, additional patterns are presented based on recent MSB filing activities.
MSBs are defined to include any person or business involved in currency exchanges, sellers or remitter of travel's
checks, or money transmitters/dealers. In 2003, there were over 150,000 independent, local, or multi-national
businesses within the United States classified as an MSB that filed over 200,000 SAR MSBs. Coincidentally, the U.S.
Postal Service is considered an MSB because it issues and redeems money orders.
On January 1, 2002, as part of the changes enacted by the U.S. PATRIOT Act, requirements went into effect for
MSBs to submit Suspicious Activity Reports (SARs). A SAR must be filed by an MSB (called a SAR-MSB) on any transactions
where the aggregate amount exceeds US $2,000 and is believed to be derived from illegal activity, serves no business or
apparent lawful purpose, or is attempting to evade any requirements of the BSA. The following examples show the first
2 pages of a SAR-MSB (page 3 is used for the narrative).
The following example represents data derived from a collection of SAR-MSBs using the Network Miner
feature contained in VisuaLinks. Using only the SUBJECT-PHONE linkage, a network was exposed showing
a strong bias for a number of different SUBJECTS using a common PHONE. In the diagram, the labels are
not displayed due to the sensitive nature of this data.
The HTTP search offered by VisuaLinks provides the ability to right-mouse click on any object and
initiate an Internet search based on any of the attribute values for the selected object. In this
investigation, the phone number was sent to Google as an HTTP search because Google maintains an online
phone book that will return the subscriber and address of the phone, if listed.
The results for this particular search showed it was listed as a discount cab company in a small
mid-western city. As shown below, the network was extended a level to show the ADDRESSES listed
for the SUBJECTS. The ADDRESSES exposed were all located in an economically depressed part of the
city known for drug-trafficking and prostitution.
The people involved in the transfer of the money were required by the MSBs filing the SAR to
list a valid phone number. Often people do not like giving their own personal information,
so they offer a number they easily remember - in this case, the number of the cab company.
Most likely the cab company is not involved in the transfer of any funds, but it happens to
be the key factor in tying together all the SUBJECTS.
For additional information regarding MSBs, please visit the following websites:
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